Letter to the Editor – Public Procurement Progress?

Fri, 12 Sept 2025

The Editor,

The second Procurement Compliance Plus (PC+) Lab on 10th September 2025 was focused on Procurement Governance, so it was a strong addition to this excellent training series for this important new legal arena. Although Procurement and Purchasing are long-established essential processes for any business, this is a novel field due to the significant changes arising from the Public Procurement & Disposal of Public Property Act (PPDPPA) 2015. The PPDPPA established effective new rules to oversee transactions in Public Money, with heavily punitive provisions, its most important feature being that oversight and penalties are now applicable to both named Public Sector Officials and Private Sector Suppliers and Contractors.

The interactive sessions were hosted by a cadre of outstanding professionals, led by the estimable Dr Margaret Rose, a long-time campaigner and educator in this field. I was a panellist, but it was also an opportunity for me to learn from and engage with a range of practitioners in this multi-faceted professional field.

The PPDPPA established the Office of Procurement Regulation (OPR) as the Statutory Oversight Agency with responsibility to ensure that these transactions are conducted in accordance with that law. Public Bodies and their Private Sector counterparts will continue to contract with each other, but in this new arrangement all of those decisions are under the oversight of the OPR.

Given the importance to our Public Interest of maximising the value obtained for every dollar of Public Money, the complexity of the PPDPPA with its various intersections with other laws, the heavy penalties and the high political stakes, there is every good reason for the professionals engaged in this arena to support this outstanding series of educational conferences.

I am also told that the OPR was invited to deliver the keynote speech at the inaugural PC+ event on 2nd May 2025, so I am very disappointed that the OPR has not attended either of these pivotal conferences. I am reliably informed that the OPR declined that invitation due to a stated fear of being accused of conflict of interest, given that it is that office which would have to rule on any complaints, challenges or other disputes. I will not stand aside while the OPR becomes yet another of our ineffective Oversight Bodies, like the Auditor General or the Integrity Commission. There is simply too much at stake here.

Apart from the over-arching point that the OPR could participate in such events without any loss of its neutrality, impartiality or fairness and more importantly, would certainly gain tremendous understanding of the challenges facing practitioners. All in all, the further bonus from OPR participation in these events would be a far greater general understanding of the issues and their context. The OPR must urgently reconsider its reluctance to attend these PC+ events, especially since its reasons appear quite rickety when one considers that  the Chief Justice gave the keynote at the inaugural event and there were three Appeal Court judges in attendance at the entire second event.

Justice and its Officers should not be so cloistered and in this new dispensation that must now include Procurement Regulators.

Afra Raymond
afraraymond.net

Letter to the Editor – Freedom of Information?

Fri, 5 Sept 2025

The Editor,

The Freedom of Information Act 1999 (FoIA) is part of what I call the “RLM Suite” of Legacy Policy – reforms championed during the tenure of then-AG Ramesh Lawrence Maharaj. That suite included the FoIA, the Judicial Review law, the activation of the Integrity Commission, the Prevention of Corruption Act and the Proceeds of Crime Act. Together they represented a deliberate attempt to empower citizens and hold public institutions accountable.

I chose the phrase ‘Legacy Policy’ to denote a particular type of law which it is all but impossible to reverse, due to its manifest good sense and popularity. So, although our Courts have widely recognised the transformative concepts at the heart of the FoIA, with leading rulings now cited internationally, with approval, as examples of progressive jurisprudence, there is still a deep dis-ease with the very Freedom of Information, at the political level.

The Act requires that Annual Reports on the operation of the FoIA be laid in Parliament, so that there could be some proper record of how this important facet of our Republic was operating. Yet, notwithstanding its parentage, just after the 2010 elections, the Freedom of Information Unit was moved to the Office of the Prime Minister, then onto Foreign Affairs (?) then the Communications Ministry. So those Annual Reports were last published in 2009, and this switch took place during the PP government, within which the UNC was the leading element.

But PNM was not to be left behind in these tactics of delay and obstruction to the fundamental democratic rights of Freedom of Information, since in 2019 there was a short-lived attempt under then-AG Faris Al Rawi to dilute the Act by extending response times to six months and so on. A short sharp campaign was mounted to confront this threat, so those proposals were quietly withdrawn.

Equally damaging are the quieter, ongoing tactics of delay and obstruction. Ministries and state agencies routinely frustrate and delay requests. In terms of my own ongoing research, since February 2025 I have been dealing with an ever-retreating timeline from NGC for information on legal fees and technical/commercial details for the Beetham Water Recycling Plant (BWRP). Partners at expensive law firms are engaged to explain the delays and promise the requested details, but those were to have been delivered over 3 months ago. While deploying the delaying tactics, NGC published details of those BWRP legal fees with this astonishing quote from NGC Chairman, Gerald Ramdeen –  “There will be no secrecy under this board,” he added. “Any request for information will be met and information disclosed.” Well I tell you eh.

It is precisely at this stage that the FoIA ought to be revised and strengthened. The law must be modernised to ensure compliance, curb abuse, and enforce real-time accountability. But revision must avoid the errors of the past. If a newly elected UNC government wishes to do better, it must act differently from the PNM before it.

The promise of the “RLM Suite” was never meant to gather dust. It was meant to anchor transparency in our democratic life. Whether we advance or abandon that legacy is now the question before us.

Afra Raymond
afraraymond.net

JAMP Citizen Perspectives: Fighting Corruption via Parliament webinar: 1 April 2025

JAMP Citizen Perspectives: Fighting Corruption via Parliament webinar: 1 April 2025

JAMP (Jamaica Accountability Meter Portal) presented the findings of its citizen survey on parliamentary accountability in the fight against corruption. Afra Raymond was invited to be a guest speaker at this webinar hosted by Jeanette Calder, Executive Director, JAMP, to give a Trinidad and Tobago perspective on accountability and transparency. Video courtesy JAMP

  • Programme Length: 00:32:09
  • Programme Date: 1 April 2025

No tax holiday for Sandals – Trinidad and Tobago Guardian

The T&T Guardian newspaper interviewed Afra Raymond on the issue of the renewed engagement of the Sandals hotel group to develop a resort in Tobago. The following article, written by Andrea Perez-Sobers and published on Friday, April 4, 2025, is presented below. Click here to read the complete article on the Trinidad and Tobago Guardian website.


If the State is to revisit and fund the Sandals mega-project in Tobago, the hotel must pay proper rates of tax and rates of pay to its staff.

There ought to be no tax holidays or concessions if the entire complex is to be funded by public money and on publicly owned land.

That’s according to former head of the Joint Consultative Council (JCC) Afra Raymond, responding to former prime minister Dr Keith Rowley’s statements on March 15 that he has personally reached out to the Sandals’ owner with a plea to take another look at the island.

“I didn’t give up after all that (first failed attempt). Recently, I spoke to the leadership at Sandals, and I asked them to come look at this again, and if I was the problem, I wouldn’t be there moving forward,” Rowley said, at the commissioning of Tobago’s new terminal of the ANR Robinson International Airport..

Continue reading “No tax holiday for Sandals – Trinidad and Tobago Guardian”

Keynote address to Regional Compliance Consultants Breakfast Seminar

Afra Raymond’s keynote speech at the 11th Anniversary Breakfast Seminar for Regional Compliance Consultants (RCC) held at Courtyard Marriott in Port of Spain on Wednesday, 22 May 2024. He spoke on the theme “The Importance and Ethics of the Compliance Profession”. The master of ceremonies was Kingsley Lewis of RCC.

  • Programme Date: 22 May 2024
  • Programme Length: 00:20:54
Courtesy RCC

A worthy NGO?

‘…We are not Serious…
Very few Conscious…
So I cannot agree with mih own Chorus!…’

from the first verse of ‘Dis Place nice’ by Brother Valentino

‘…Your silence will not protect you…’

Caribbean Philosopher Audre Lorde, on the false beliefs and toxic consequences earned from calculated or cowardly silences

“Last call to all corporates. Support this worthy NGO if you can,” was the rallying note from an erstwhile Colleague who had served on the Board of the T&T Transparency Institute (TTTI). This was an appeal to boost ticket sales for the TTTI’s fundraising dinner carded for 22 May 2024, but it ultimately provoked me into making these pointed observations, so here goes.

For a some years now, it has become increasingly clear that TTTI had drifted from its purpose with less and less work, of lower and lower quality, emerging from that NGO of which I am an Ordinary Member. One can scarcely believe that this was once a vibrant, outspoken and well-informed NGO with dedicated leaders such as Victor Hart, Richard Joseph, Deryck Murray and Annette des Iles, not that we can ever forget the recently departed Reginald Dumas and Boyd Reid.

I am making serious alIegations, so let me show the extent to which the TTTI has strayed from its purpose. Apart from its bewildering silence and lack of support during the recent campaign to have the Public Procurement & Disposal of Public Property Act proclaimed, one can scarcely recall the last time any TTTI Representative was on TV, Radio or in the printed Press.

TTTI’s webpage offers a June 2021 item as the latest in its ‘Press & Media Releases’ tab (almost three years ago), with its latest ‘News’ item being the January 2024 ‘Launch of the 2023 Corruption Perceptions Index’, to which I will return.

TTTI’s IG account seems to have been captured by fete-promoters, with scandalous content, which I notified TTTI about since early December 2023, but the contents are still there. [N.B. The account, with 2 posts and 10 followers to date, is online.]

TTTI’s FB page is moribund with not one single local issue highlighted in the whole of 2023 (!);

On Twitter, TTTI is also moribund (only 146 followers), with its most recent post being an anodyne International Women’s Day flyer dated 8th March 2023. The most recent local issue or event is its Town Hall meeting on 27th October 2020 against Gender-Based Violence in T&T. Clearly, both of those are important issues, but what is the nexus with TTTI’s mission?

The newly-elected TTTI Chair, Ms Donna Jack-Hill, presented the 2023 Corruption Perceptions Index on 30th January 2024 and some of her comments on the need for an independent and robust Judiciary were widely misunderstood to be pointed at T&T’s Judicial Officers. A strong backlash emerged with Press Releases from the Law Association and the Judiciary, together with several newspaper articles/editorials.

As unfortunate as it was, the misreporting of those TTTI statements and the public backlash presented a good opportunity to clear the air and for the new Chair to have reset standards. It is my view that this required a timely and solid response from TTTI, since the Press Reports on the 2023 CPI, were deeply critical of TTTI’s credibility. I am not aware that any public comment or clarification was made, so perhaps this Gala Dinner will be yet another chance to correct the record and find a new voice, albeit too long in coming. We will see.

In 100 years’ time, historians will struggle to understand how in a land like ours, an organisation like ours (yes, I am a true member of TTTI) could have said so little at a time like this.

Careerists who are concerned to bolster their CV and careful to avoid offending anyone with more power or money than themselves are a clear and present danger to our Republic, especially when they maintain an intentional silence in the face of epic wrongdoing.

Sad to say, but TTTI’s apparent reluctance to clarify or raise its voice is redolent of the evasions and strategic silences of our ruling class. Silence is the Enemy of Progress.

I welcome a response to these issues from TTTI.

Afra Raymond
afraraymond.net
This is my critique of the output of the TTTI, published on Sunday 19th May 2024 in the T&T Express, T&T Guardian and T&T Newsday, it also appeared on Wired868 – https://wired868.com/2024/05/21/dear-editor-is-tt-transparency-institute-really-a-worthy-ngo/.

Letter to the Editor – Come Again, Minister West

The Editor,

The Minister of Public Administration [MPA] responded to my previous letter in the Sunday Edition of 29 October 2023, the very next day.

TTT Live Online

Minister West disputed my citations of the monthly rent of $600,000 and the 23,000sf floor area of those offices, as well as my conclusion that the resulting rent of $26psf signified ‘flagrant corruption’.  The Minister went on to say that the correct monthly rent was $500,000 and that the floor area was in fact 43,295sf, which equates to a rent of $11.55psf.  

As I indicated in the previous letter, my figures were drawn from both the PM’s public statements and the immediately subsequent Express article.  The PM emphatically stated the monthly rent to be $600,000 at the post-Cabinet Media Briefing on Thursday 23rd March 2023 and the 23,000sf floor area is in that Express article of 11 March 2023 – $40M SPENT ON NEW DPP OFFICE – but I have not been able to establish any other source for that citation.

Start 06:24, End 11:46

Minister West gave no citations in support of the claimed figures and I reject entirely the unstated position too often taken by our rulers that “if I say so, is so.”  I gave my citations, so given that MPA is relying upon the Lease and Valuation Report for this property to challenge my citations, those documents should be published now, to “show us their workings.”

Of course, if the State was able to rent those high-quality Park Court offices at $11.55psf, I have no difficulty in accepting that as a commendable negotiation outcome, notwithstanding the other aspects which have stirred public concern on this matter.

The AG told the Standing Finance Committee of Parliament on 19th October 2023 that the Public Money spent on that property was $55,551,443.93  (at 4:49:45).  Given the understandable and widespread public concerns arising from this large-scale expenditure, it would be an important step towards transparency for the MPA to issue details of how those monies were spent.  The $500,000 monthly rent stated by Minister West would amount to $19.0M over the three years and two months that property was leased.  The cost of the improvements and modifications has repeatedly been stated as $24M.  The total of those two figures is only $43M, so I have certain concerns.  I am sure that a statement clarifying those details can be quickly issued.

Finally, this entire issue of the wasted Public Money on these offices which were never occupied is rooted in the requirement for a proper Needs Assessment before committing to any Procurement.  If a Needs Assessment was done in this matter, there is certainly good reason to re-examine that process to ensure that we avoid such waste in the future.

The Minister also mentioned that these details are available on the ‘Property & Real Estate portal’ at https://pmis.gov.tt/, but this as yet inaccessible to the public.  Why not make the entire database readily accessible to the public, just like the EBC list?  

Afra Raymond
afraraymond.net

Keynote address at launch of Call To Action for Social Change Foundation

Afra Raymond was asked to deliver the keynote address at the launch of the Call To Action for Social Change Foundation held at the CLL Auditorium at The UWI campus, St Augustine, Trinidad and Tobago. His speech was entitled, “The role of civil society and its importance in a well-functioning society.” Video courtesy Call To Action

  • Programme Date: 10 September 2023
  • Programme Length: 00:14:44
Video courtesy Call To Action for Social Change Foundation

Manufactured Consent in new Public Procurement law?

“Ambiguity and silence is the enemy of #ethics and #integrity.”

Richard Bistrong @Richardbistrong Twitter feed. Dec 5, 2019

“‘Manufactured consent’ is supported by…effective and powerful ideological institutions that carry out a system-supportive propaganda function by reliance on market forces, internalized assumptions, and self-censorship, and without overt coercion.”

Noam Chomsky, Manufacturing Consent: The Political Economy of the Mass Media 1988, (New York: Pantheon Books)

The Public Procurement & Disposal of Public Property Act (the Act) was fully proclaimed on Wednesday 26 April 2023, which makes that one of our Republic’s truly historic days by any measure.

I welcomed the decision to proclaim the Act, since even with the damaging suite of 2020 exemptions, this is a tremendous step in the right direction of Accountability, Transparency and Good Governance so that we can achieve improved Value for Money in our Public Affairs. The Private Sector Civil Society Group wrote and lobbied for this important law, so this is the result of long-term, collective effort. We owe serious appreciation to those who persisted when this was a faraway vision.

Continue reading “Manufactured Consent in new Public Procurement law?”

VIDEO: “Caribbean Bridges” Ep. 4 – TIEF from TIEF MEK GOD LAUGH!

It is no laughing matter when it comes to corruption in high and low places. Little and big bribes, kickbacks and dishonesty…Can it be cleaned up?” Caribbean journalist from Barbados, Julian Rogers interviewed Afra Raymond along with Dr. Troy Thomas former Head of TI Guyana, who successfully challenged the EXXON-Mobil contract in October 2020 in Guyana’s High Court and Ms. Jeanette Calder the Executive Director of Jamaica Accountability Meter Portal on transparency and corruption on his show “Caribbean Bridges”. Video courtesy Caribbean Bridges.